NC0000752_Correspondence_20031219

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North Carolina Department of Environment and Natural Resources
Division of Air Quality
Michael F. Easley, Governor
Mr. William J. Cooper, Jr.
Roanoke Rapids Mill Manager
International Paper
P.O. Box 580
Roanoke Rapids, NC 27870
William G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
December 19, 2003 s�
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JA N 6 2004 DIV. OF WATER QUALITY
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Subject: Roanoke Rapids Mill Twelve Month Compliance Date Extension for Pulp and Paper
Maximum Achievable Control Technology (MALT) I Phase II Rule [40 CFR 63.443]
Dear Mr. Cooper:
The Division of Air Quality (DAQ) has received and reviewed your November 26, 2003 request for
a further 4-month extension to the compliance deadlines for the Pulp and Paper MACT I Phase II Rule [40
CFR 63.443] for your Roanoke Rapids Mill. Based upon your Environmental Innovation Proposal
submitted November 26, 2003, the DAQ grants International Paper (IP) an additional extension of 4 months
to the MACT I Phase II compliance deadline, making the new termination date April 16, 2007.
The MACT I Phase II sources include filtrate tanks, foam towers, brown stock washers and several
clean and recycled water streams.
DAQ grants IP the further extensions provided you revise your Title V permit application as soon
as practicable to incorporate the conditions of the compliance extension and that you fulfill requirements
related to the compliance extension and innovation proposal. There is no extension for MACT I Phase II
compliance testing beyond the termination date granted. DAQ expects International Paper to verify
compliance by the end of this 12-month compliance extension with the innovation project as it may
ultimately be approved.
This compliance extension is to allow IP jointly with the Department of Environment and Natural
Resources (DENR) and EPA Region IV the necessary time to complete review and approval of an
Environmental Innovation Proposal at the Roanoke Rapids Facility. Without the time extension, IP has
consistently maintained you would have to abandon the innovation proposal that shows greater emission
reductions for odor, hazardous air pollutants (HAPs), and toxic air pollutants, including hydrogen sulfide,
using novel process improvements and controls, than would be attained otherwise by conventional
measures. DAQ notes also that the review and approval process for the proposal is novel and
unconventional.
Compliance Milestones
The new termination date for the MACT I Phase II compliance extension is April 16, 2007, twelve
months from the date in the rule. Compliance must be demonstrated by this date. The following dates
serve as milestones for the steps taken toward MACT I Phase II compliance:
1641 Mail Service Center, Raleigh, North Carolina 27699-1641 One
2728_,Capital Blvd., Raleigh, North Carolina 27604 NorthCarolina
Phone: [phone] / FAX [phone] / Internet: www.ncair.org Naturally
An Equal 0 q pportunity/Affirmative Action Employer - 50 /o Recycled/10 /o Post Consumer Paper

Mr. William J. Cooper, Jr.
December 19, 2003
Page 2
• Obtain DAQ and EPA approval for the innovation proposal plans by April 16, 2004.
• Complete performance testing and hold test results for determination of equity with or compliance
with the MACT I Phase II regulations by April 16, 2007.
In the unforeseen event that the review and approval process for you innovation proposal cannot be
successfully concluded, then IP must implement the original MACT standard. However, this would be on a
compliance schedule extended by the twelve month, granted in this letter or such other schedule consistent
with section 2.6 of the Innovation Proposal. S
DAQ remains hopeful that the innovative plan may be approved to realize ifs potential benefits. If
you have any questions or comments, please contact Lee Daniel at [phone] or me.
Sincerely,
r
B. K h Overcash, P.E.
BKO/lad
cc: William G. Ross, Jr., Secretary, NC DENR
Robin Smith, Assistant Secretary Planning/Policy, NC DENR
James Carter, Assistant Secretary Operations and Development, NC DENR
James Palmer, Regional Administrator, EPA Region IV
Howard D. Lienert, P.E., Manager, Environmental Regulatory Affairs, International Paper
Gary Hunt, Director, Division of Pollution Prevention and Environmental Assistance
Alan Klimek, Director, Division of Water Quality
Wayne Cook, Supervisor, Wilmington Regional Office
Ernie Fuller, Supervisor, Raleigh Regional Office
Lee Daniel, Chief, Technical Services Section
Laura Butler, Chief, Permitting Section